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Section 147

Latest Articles


Addition Deleted Due to Lack of Corroborative Evidence in Search-Based Case

Income Tax : ITAT held that additions based solely on third-party search material without independent evidence or cross-examination are invalid...

April 21, 2026 507 Views 0 comment Print

Sections 147 & 148 of Income-Tax Act: Reassessment From ‘Reason to Believe’ to ‘Information’

Income Tax : A detailed look at how the Finance Act, 2021 reshaped Sections 147–151, introduced Section 148A, and reduced limitation periods ...

February 28, 2026 873 Views 0 comment Print

Jurisdiction for Reassessment Notices Clarified to End Faceless AO Disputes

Income Tax : The Finance Bill, 2026 clarifies who can issue notices under sections 148 and 148A. It confirms that only jurisdictional Assessing...

February 2, 2026 2844 Views 0 comment Print

Can Penalty be Levied on Delayed Annual GST Return?

Goods and Services Tax : The court held that once late fee is imposed for delayed annual return filing, a further general penalty is not permissible. Secti...

January 20, 2026 18264 Views 2 comments Print

Reassessment Quashed as Limitation Ran From Original Assessment, Not Revision

Income Tax : The issue was whether an assessment could be reopened after four years. The Court held that full disclosure by the taxpayer barred...

January 8, 2026 423 Views 0 comment Print


Latest News


Budget 2024: Block Assessment provisions for Section 132 & 132A Searches

Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...

July 23, 2024 2193 Views 0 comment Print

Budget 2024: Amendments to Income-tax Assessment & Reassessment Provisions  

Income Tax : Discover how Finance Act 2021 revamped assessment and reassessment procedures under Income-tax Act, impacting notices, time limits...

July 23, 2024 4314 Views 0 comment Print

Request to clarify on SC judgement on Section 148 notices

Income Tax : Income Tax Gazetted Officers’ Association requested CBDT to issue Clarification in respect of the judgement of Hon’ble Supreme...

May 12, 2022 7458 Views 0 comment Print

Indiscriminate Income Tax notices without allowing reasonable time

Income Tax : In view of Indiscriminate notices by income Tax Department without allowing reasonable time it is requested to Finance Ministry an...

March 20, 2022 13332 Views 0 comment Print

Extend Time Limit for Income Tax Assessment time barring on 31.3.2022

Income Tax : Lucknow CA Tax Practicioners Association has made a Representation to FM for Extension of Time Limit for Assessment cases time bar...

March 20, 2022 42774 Views 2 comments Print


Latest Judiciary


Section 68 Additions: Favourable Remand Report Shields Assessee

Income Tax : The issue was deletion of additions on unsecured loans treated as unexplained cash credits. The tribunal upheld deletion, holding ...

May 2, 2026 93 Views 0 comment Print

Delay Condoned with Cost: ITAT Grants Fresh Chance, Slams Non-Compliance

Income Tax : The issue involved dismissal of appeal due to delay and non-appearance. The tribunal condoned the delay citing medical reasons and...

May 2, 2026 114 Views 0 comment Print

Reassessment After 4 Years Quashed as No Failure to Disclose Material Facts: Bombay HC

Income Tax : The issue was whether reassessment could be initiated after four years without fresh evidence. The court held such reopening inval...

May 2, 2026 108 Views 0 comment Print

Reassessment Quashed for Wrong Sanction: ITAT Bangalore Strikes Down 147 Order for Breach of Section 151

Income Tax : The issue was whether reassessment notice issued without approval from the correct authority is valid. The tribunal held it invali...

May 2, 2026 93 Views 0 comment Print

Reassessment Notice Time-Barred as Issued Beyond Limitation Period: Karnataka HC

Income Tax : The Court held that reassessment proceedings must be initiated within the statutory time limit. It found the notice issued after t...

May 1, 2026 453 Views 0 comment Print


Latest Notifications


ITO doesn’t have jurisdiction to issue notice to NRI: ITAT Chandigarh

Income Tax : ITAT Chandigarh held that ITO Ward-3(1), Chandigarh had no jurisdiction to issue notice to an NRI and hence consequently the asses...

April 11, 2025 5745 Views 0 comment Print

Central Government Rescinds 6 Central Excise Notifications issued in 2022

Excise Duty : Notification No. 29/2024-Central Excise rescinds six 2022 excise notifications in the public interest, effective immediately. Deta...

December 2, 2024 813 Views 0 comment Print

Instructions to AO’s for initiating section 147 proceedings in I.T. e-Verification cases

Income Tax : Learn how to initiate proceedings under section 147 of the IT Act in e-Verification cases. Detailed instructions for Assessing Off...

March 19, 2024 10272 Views 0 comment Print

Instructions to AO’s for initiating Section 147 proceedings in e-Verification cases

Income Tax : Explore e-Verification Instruction No. 2 of 2024 from the Directorate of Income Tax (Systems). Detailed guidelines for AOs under I...

March 1, 2024 5784 Views 0 comment Print

Limitation date for reopening cases related to Ashish Agarwal judgment

Income Tax : Supreme Court in the matter of Shri Ashish Agarwal, several representations were received asking for time-barring date of such cas...

February 6, 2023 5880 Views 0 comment Print


Mere non-attendance of summons cannot be reason to disbelieve genuineness of transaction

October 7, 2023 1872 Views 0 comment Print

ITAT Mumbai held that the assessee had furnished sufficient evidences to justify the genuineness of the payments and therefore their mere non-attendance of summons, cannot be reason enough to disbelieve the genuineness of the transactions with them. Accordingly, addition u/s. 69C deleted.

Addition u/s. 68 unsustainable as genuineness of depositors proved

October 6, 2023 1728 Views 0 comment Print

ITAT Jodhpur held that addition under section 68 of the Income Tax Act towards unexplained credit unsustainable as genuineness of the depositors provided by filing confirmation, affidavits, bank statement, etc.

Section 10(23C)(iiiab) exemption not available to society not substantially financed by government

October 6, 2023 5376 Views 0 comment Print

ITAT Raipur held that assessee-society not being wholly and substantially financed by the government is not entitled for claiming exemption under Section 10(23C)(iiiab) of the Income Tax Act, 1961.

DTVSV Benefit Rejection Over pending Non-Tax Arrears Prosecution Unjustified

October 5, 2023 1155 Views 0 comment Print

Bombay High Court held that rejection of benefit under Direct Tax Vivad Se Vishwas Act 2020 (DTVSV) unjustified as pendency of prosecution was in respect of any issue and not in respect of tax arrears.

Disallowance u/s 14A without scrutinizing books of accounts is unwarranted

October 5, 2023 1023 Views 0 comment Print

Delhi High Court held that disallowance under section 14A of the Income Tax Act without scrutinizing the accounts of the respondent/assessee unjustified in law and hence liable to be set aside.

Reopening of completed assessment beyond four years unjustified as material facts fully and truly disclosed

October 5, 2023 939 Views 0 comment Print

ITAT Raipur held that reopening of completed assessment beyond four years without failure on the part of the assessee to fully and truly disclose all the material facts is unjustified and liable to be quashed.

Disallowance restricted to 0.5% of guarantee value in corporate guarantee to AE

October 4, 2023 2199 Views 0 comment Print

ITAT Chennai held that the corporate guarantee to Associated Enterprise (AE) is an international transaction and it has to be assessed at 0.5% of the corporate commission. Hence, directed AO to restrict the disallowance at 0.5% of the guarantee value.

Amendment to provisions of section 50C(1) is retrospective in nature

October 3, 2023 3669 Views 0 comment Print

ITAT Hyderabad held that amendment to provisions of section 50C(1) of the Income Tax Act is retrospective in nature and hence the value adopted or assessed or assessable by the Stamp Valuation Authority on the date of agreement has to be taken for the purpose of full value of the consideration.

Addition u/s 68 of Income Tax Act based on retracted statement unsustainable

October 3, 2023 3411 Views 0 comment Print

ITAT Mumbai held that addition u/s. 68 of the Income Tax Act merely based on statement of the key person which was retracted subsequently unsustainable as genuineness, identity and creditworthiness proved.

Deduction u/s 80IA(4) of Income Tax Act available to developer of infrastructure facility

October 2, 2023 2682 Views 0 comment Print

ITAT Ahmedabad held that the assessee is engaged in development of the infrastructure facility and therefore, a developer, which confers right of eligibility to the assessee to claim benefits u/s. 80IA(4) of the Income Tax Act. Mere referring assessee as a contractor in the agreement cannot deprive assessee from claiming deduction u/s. 80IA(4).

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